Opinion
12271-20 12274-20
04-27-2023
JACKSON STONE SOUTH, LLC, JACKSON SOUTH INVESTMENTS, LLC, TAX MATTERS PARTNER, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall Judge
These consolidated cases were called for trial at the Special Trial Session of the Court which commenced on March 13, 2023, in Washington, D.C.
On March 20, 2023, petitioners lodged a: (1) Motion for Reconsideration of Order Denying Motion in Limine to Exclude Proposed Exhibits 401-R and 403-R and Testimony of Matthew Sullivan at docket No. 12271-20 (docket entry 337) and at docket No. 12274-20 (docket entry 343), and (2) Motion in Limine to Exclude Proposed Exhibits 400-R and 402-R and Testimony of Matthew Sullivan at docket No. 12271-20 (docket entry 339) and at docket No. 12274-20 (docket entry 345). These two motions filed by petitioners inadvertently disclosed personal information.
On March 22, 2023, petitioners filed with the Court redacted versions of the motions lodged on March 20, 2023, in accordance with Rule 27(h), Tax Court Rules of Practices and Procedures: (1) Motion for Reconsideration of Order Denying Motion in Limine to Exclude Proposed Exhibits 401-R and 403-R and Testimony of Matthew Sullivan at docket No. 12271-20 (docket entry 346) and docket No. 12274-20 (docket entry 357), and (2) Motion in Limine to Exclude Proposed Exhibits 400-R and 402-R and Testimony of Matthew Sullivan at docket No. 12271-20 (docket entry 348) and docket No. 12274-20 (docket entry 359). Upon due consideration and for cause appearing more fully in the transcript of the above-referenced proceedings, it is
ORDERED that petitioners' Motion for Reconsideration of Order Denying Motion in Limine to Exclude Proposed Exhibits 401-R and 403-R and Testimony of Matthew Sullivan at docket No. 12271-20 (docket entry 412) and at docket No. 12274-20 (docket entry 433), filed on March 20, 2023, is hereby sealed from the record. It is further
ORDERED that petitioners' Motion in Limine to Exclude Proposed Exhibits 400-R and 402-R and Testimony of Matthew Sullivan at docket No. 12271-20 (docket entry 413) and at docket No. 12274-20 (docket entry 434), filed on March 20, 2023, is hereby sealed from the record.